20180705Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
REC E IVE D
Zfil$,iUL-5 Pll l:30
COMMENTS OF THE
COMMISSION STAFF
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF THE)
IDAHO DEPARTMENT OF
ADMINISTRATION FOR AN EXEMPTION
FROM THE IDAHO PUBLIC UTILITIES
COMMISSION'S MASTER METERING
RULES FOR ELECTRIC UTILITIES AND THE
IDAHO POWER MASTER METERING
STANDARDS.
CASE NO.IPC.E.18-08)
)
)
)
)
)
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The Staff of the Idaho Public Utilities Commission, through counsel, comments as
follows on Idaho Department of Administration's (IDOA) Petition for an Exemption to the Idaho
Public Utilities Commission's Master Metering Rules for Electric Utilities and the Idaho Power
Master Metering Standards (the Petition).
BACKGROUND
On April 13,2018, the IDOA petitioned the Commission for an exemption from the
Commission's Master Metering Rules for Electric Utilities (IDAPA 31.26.01) for the State of
Idaho's Chinden Office Complex (the "Campus"), which was recently purchased from HP Inc.,
formerly known as Hewlett Packard Company. IDOA also seeks a corresponding waiver of
Idaho Power Company's Master Metering Standards in Rule E to Tariff No. 101.
THE MASTER METERING RULES AND STANDARDS
Commission Master Metering Rule 103 (IDAPA 31.26.01.103) states:
ISTAFF COMMENTS JULY 5,2018
st0r.l
No unit of commercial buildings and shopping centers shall be master-
metered for electric service after July 1, 1980, if the units for their tenants
contain an electric space heating, water heating, or air-conditioning (space
cooling) unit that is not centrally controlled and over which the unit's
tenants individually control electric usage. Tenants in otherwise master-
metered buildings whose electric load or who operate appliances whose
electric load exceeds the individual metering threshold found in the utility's
tariffs must be individually metered.
Idaho Power's master metering standard in Section 4 of Rule E to Tariff No. 110 is
nearly identical to the Commission Master Metering Rule 103. Both the standard and rule
require utilities to individually meter commercial buildings where the tenants control their own
electric space heating, water heating, or air-conditioning appliances.
IDOA has petitioned the Commission for an exemption to the master metering rule and
standards as they relate to the state's recent purchase of the Campus from HP Inc.
The state leases more than 800,000 square feet of private property. Leases for about one
third of that space will expire in the next five years. In2077, the Idaho Legislature concluded it
would be a wise use of taxpayer dollars for the state to buy the Campus-which consists of about
200 acres, eight separately numbered buildings, a cafeteria building, multiple outbuildings, a
picnic shelter, trails, sports fields, and parking areas-for use as a single-destination complex for
multiple state agencies that currently lease premises elsewhere. The state thus purchased the
Campus from HP Inc. Petition at2-4. Idaho Power provides electrical service to the Campus
through a substation, and the electricity is then distributed through a network throughout the
Campus to the different buildings and other structures. Id. at3.
With the state's purchase of the Campus, the state also entered a Facilities Lease with the
IDOA that requires IDOA to operate and maintain the Campus. In accordance with the state's
purchase of the Campus from HP Inc., the IDOA also was required to lease back part of the
Campus to HP Inc. HP Inc. was to be the sole tenant of Campus Buildings I,3,5, and 7, the
cafeteria building and certain connecting corridors and outbuildings serving these buildings.
IDOA also was to assume HP Inc.'s existing leases with HP Inc.'s existing on-Campus tenants,
including Hewlett Packard Enterprise Company (Building 4), Enterprise Services LLC (part of
Building 2), and Sykes Enterprises, Incorporated (Building 8). IDOA also entered a new lease
with another tenant, First Technology Federal Credit Union Boise, which had been serving HP
Inc.'s employees at the Campus in part of Building 2 as part of a master lease with HP Inc. Id. at
4-6.
2STAFF COMMENTS JULY 5,20T8
The IDOA's leases with the different on-Campus tenants expire as follows: HP Inc. has
an initial term of seven years, and options to renew for two five-year terms; Hewlett Packard
Enterprise Co. expires July 31,2020; Enterprise Service LLC expires June 31,2018; and Sykes
Enterprises, Incorporated expires June 30, 2020, with two options to extend the term for five-
year periods; and First Technology Credit Union expires March 31,2019, with an option to
extend to March 31,2022- Id. at 4-5. IDOA maintains it has no authority to lease the Campus to
any private entity outside of the existing leases at the Campus. Rather, the Campus will be used
as a complex for state agencies. As the leases expire, state agencies will transition to the
Campus. The Idaho State Tax Commission and Industrial Commission will move to Building 2
this year. Id. at7. And, except for the small credit union suite, state agencies will fully occupy
Campus Buildings 2,4,and6by mid-2020. Id. at5.
IDOA requests an exemption to the Commission's master metering rule and Idaho
Power's corresponding standard so IDOA can install the HP Inc.-required sub-meters, require
HP Inc. to pay the actual costs of its electric use, and otherwise facilitate the IDOA's ability to
better operate and manage the Campus. Id. at 7-2, and 12. IDOA notes its lease with HP Inc. is
consistent with the Commission's master metering rules because electric charges are transparent
to HP Inc. and based on protocols developed by both parties; HP Inc.'s Supervisory Control and
Data Acquisition (SCADA) system and audit process in the lease ensure HP Inc.'s electric costs
are its actual costs; and HP Inc. has full control of its leased premises electric hot water systems,
air systems, vacuum systems, and process water systems. IDOA states these provisions enable
HP Inc. to control the efficiency of its electric use based on its actual use and business needs. Id.
at2 and ll.
STAFF ANALYSIS
Staff recommends the Commission authorize a limited exemption to Master Metering
Rule IDAPA3l.26.0l.l03 and waive the requirements of Master Metering Standards Rule E
from IPUC No. 19, Tariff No. 101 for the State of Idaho Chinden Office Campus as laid out in
more detail below. Staff believes this is reasonable because the situation is temporary-no
waiver will be needed when the Campus is either individually metered or wholly occupied by
state agencies-and because the IDOA's proposal to sub-meter HP Inc. with SCADA will
effectively preserve the price signal which master metering rules exist to protect. Staff
recommends that these exemptions expire when the Campus buildings are individually metered,
aJSTAFF COMMENTS JULY 5,20I8
upon termination of the existing leases for each Campus building, or when the Campus becomes
wholly state occupied, whichever comes first.
Introduction
After the State of Idaho purchased the Campus, IDOA asked Idaho Power to manage the
Campus through the Company's Rule M Facilities Charge Service. During meetings with Staff,
IDOA indicated that Idaho Power's management of the State of Idaho's Capital Mall complex
under a facilities charge agreement has worked well and that IDOA would like to establish a
similar arrangement for the Campus.
When Idaho Power inspected the Campus to determine if it could provide facilities
services, it determined that the Campus electric system does not use standard Idaho Power
electric equipment or configurations. Because the Campus electric system is non-standard, Idaho
Power does not have the equipment inventory or professional expertise to serve the Campus
under a facilities charge arrangement.
In meetings with Staff, Idaho Power explained that the electrical distribution network
connecting Buildings 1 through 7 is very complex, but functional. The Campus' Point of
Delivery (POD) is the Idaho Power Substation on Cloverdale Road. The substation has two 12.5
KV feeders; one goes to Building I and the other goes to Building 8, which is individually
metered. Buildings I through 7 are not individually metered. Instead, they are served through a
centralized switching system in Building l. In addition to Buildings 1 through 7 being
interconnected rather than individually metered, the Campus includes five electric chillers that
provide air conditioning to all eight buildings. Staff understands this unique configuration
results from the Campus and its electric system being built and expanded behind Idaho Power's
POD over thirty years to meet HP's specific needs.
After a series of inspections, Idaho Power informed IDOA that the Company could not
serve the Campus under a facilities charge agreement unless significant investments were made
to align the Campus with its standard equipment. Idaho Power also informed IDOA that because
the Campus buildings are not owner-occupied (i.e., occupied by state agencies) and are not
individually metered, the Campus would need a waiver from the Commission rules prohibiting
mastering metering to maintain the existing leases. The IDOA then authorized Idaho Power to
conduct a construction study to determine the necessary investment to make the Campus suitable
4STAFF COMMENTS JULY 5,2018
for a facilities charge agreement, and engaged Commission Staff about the procedure for
obtaining of a waiver from the master metering rules.
History of Master Metering
In 1980, the Commission adopted Rules and Regulations Governing Master Metering of
Electric Service (Master Metering Rules) by Order No. 15556. In its Order, the Commission
stated that its decisions were based "not only on the conservation goals of [the Public Utility
Regulatory Policies Act of 19781, but also upon goals of fostering and maintaining direct
relations between electric utilities and their customers and of equitable treatment of the ultimate
consumers of electricity".l The rules were based on four premises:
1. Individually metered tenants who are responsible for paying their own electric
bills use less and waste less electricity than master-metered tenants .. .;
2. The ultimate consumers of electric energy are better served by a direct customer
relationship with the utility than by disguising utility costs in the rent or by the
landlord playing the role of the public utility ...;
3. It is inequitable for electric consumers to pay more or less than the cost of
electricity which they consume themselves . ..; and
4. The adoption of easily understood rules capable of immediate application without
lengthy or costly studies or analyses is a better means of drawing reasonable lines
allowing or disallowing master metering than rules based upon complex cost-
benefit analyses that ignore unquantifiable benefits of individual metering. Order
at2.
Previous Master-Metering Waivers
Since adoption of the Commission's Master Metering Rules in 1980, the Commission has
received six formal requests for exemption. Five were granted, and one was withdrawn before
an order issued.
Five exemption requests involved new construction, three of which were for residential
assisted living facilities. A fourth request involved a city-owned facility providing transitional
I Order No. 15556 at I
5STAFF COMMENTS JULY 5,2018
housing and efficiency apartments to the homeless and low-income communities. The fifth
request was for a high-rise building with residential units and retail and office space.
In each case, the efficiency of the building and the ability for tenants to respond to the
price signal was a factor in granting the waiver. The assisted living facilities and the low-income
housing all included a host of energy efficiency measures. While residents of the assisted living
facility controlled their own space heat, it was included as a part of their rent, so they would not
have received a price signal even if they were individually metered. Residents of the homeless
and low-income housing community do not pay for their housing or utilities, so they would not
receive the price signal even if units were individually metered.
The high-rise mixed-use building met particularly high efficiency standards-itusedT5o/o
less energy than a comparably sized building. While the retail tenants of the building were
individually metered, the Commission found that the extremely low energy use of the building
dramatically decreased the need to send a price signal to the office space and residential unit
occupants.
In several cases, the Commission found that the nature of the proposed facility in both
design and operation "does not lend itself well to providing the conservation signals that would
otherwise be provided through individual metering and billing."2 In four cases, the Commission
specified that the exemption applied only so long as the facility was used for its original purpose
or a similar type facility.3 In those same four cases, the Commission required that the buildings
incorporate energy efficiency measures into the building design.
Only one exemption request involved an existing commercial property, which in that way
is similar to the IDOA's request for the Campus. Idaho Power and Sinclair Oil, dba Sun Valley
Company, requested a rule exemption in conjunction with approval of the sale and transfer of
distribution facilities at the Sun Valley Resort. Sun Valley wanted to remove the meters and
reconfigure the service line, so all l9 tenants in the mall area would be served under a master
meter arrangement between Idaho Power and the Sun Valley Company. The cost of electricity
would be incorporated into tenants' lease rates. The Commission approved the waiver because
its scope was limited and only 4 of the 19 tenants were paying Idaho Power directly for their
usage even when they were individually metered.
2 See Case No. IPC-E-96-07, Order No 26451.
3 See Case No. IPC-E-91-21, Order No .23936; Case No. GNR-E-94-01, Order No. 102; Case No. IPC-E-96-07, Order
No. 26451; and Case No. WWP-E-96-05, Order No. 26512.
6STAFF COMMENTS JULY 5,2018
The IDOA waiver request does not align closely with any of the previously granted
waivers. However, the IDOA's situation differs from previous requests in one significant way: it
is temporary. The Campus needs the waiver only until the Campus buildings are individually
metered or wholly occupied by state agencies. Since IDOA intends to transition the entire
Campus to state occupancy, Staff believes it is reasonable to recommend a limited waiver that
would allow IDOA to honor its lease agreements and facilitate the transition to state occupancy.
However, Staff also recommends that the waiver expire no later than when HP's final lease
extension option ends in 2035 to ensure that the current situation is not later construed as a
precedent that might encourage future petitioners to circumvent the master metering rules.
Existing Leases at the tauput
Campus buildings were not individually metered rvhen HP owned the Campus, but HP
did not require a waiver from master metering rules because HP and its related businesses
occupied all of the buildings that were not individually metered (Buildings I through 7).
Building 8, which is occupied by an unrelated entity, was separately metered when it was
connected in 2013. However, when the state purchased the Campus in2017, it agreed to
temporarily maintain existing leases to HP and the other commercial tenants in buildings that are
not individually metered. This arrangement is not consistent with the master metering rules and
prompted IDOA to request a waiver.
The Campus currently has four non-state agency tenants in unmetered buildings. As the
existing leases expire, the IDOA indicated that it plans to transition the Campus to state agencies.
If the entire Campus were occupied by state agencies, no waiver would be necessary. However,
the transition period to full state occupancy is very long. As shown in Table 1, some leases
expire by or before2020, others have options to extend until2030, and HP Inc.'s lease can be
extended until 2035.
The lease arrangement for HP Inc., which occupies over half the Campus, differs from
the other assumed leases. The HP Inc. lease allows more flexibility to renew, with a seven-year
initial term and two subsequent five-year renewal options. Although, the HP Inc. lease could
continue for 17 years, it could also be terminated beginning in December of 2022. In addition,
the HP Inc. lease requires the IDOA to provide utility separation, sub-metering or metering, and
electric billing for the actual cost of electric service. Other tenants have the cost of utilities
included in the monthly rent, similar to common commercial lease agreements.
7STAFF COMMENTS JULY 5,2018
Staff notes that IDOA could re-negotiate any of these leases beyond the currently
identified dates. IDOA may have a particular incentive to extend the HP Inc. lease to keep HP
located in Idaho. Besides extending the existing leases, IDOA could also rent space to non-state
tenants. Renting space to anyone other than state agencies without individual metering would
require a waiver.
Table 1: State of Idaho Chinden Campus Buildings, Tenants, and Leases (Id. at 5-6)
Sub-metering and Billine
State agencies and commercial tenants at the Campus, except HP Inc., operate under
variations of a "full service" lease where electric charges are built into a base rent payment.a
This type of lease is very common because it provides tenants with a predictable rent payment
over the term of the lease and protects them from cost increases and month-to-month expense
fluctuations. While the absence of a direct utility bill means the price signal is lost, Staff does
not oppose this arrangement for state agencies because they are all part of the same broader
organization. Additionally, Staff does not oppose this arrangement for the other Campus
4 In Building 2, the First Technology Federal Credit Union, there is an "additional rent" component in the lease for
after-hours HVAC charges. Hewlett Packard Enterprise Company, also in building 2, and Enterprise Services LLC
in Building 4,have electric charges entirely built into a base rent payment. Sykes Enterprises in Building 8, has an
"additional rent" component specified in their lease for excess energy use over a defined usage cap.
8
Building Tenant Lease
Expiration
Renewal/
Extension
Additional Lease
Options
1,3,5,7 HP Inc.2025 2030,
2035
May terminate in
2022, Two five-year
extensions
Cafeteria HP Inc.60 day notice
2
(Shared)
Enterprise Services
LLC June 30, 2018
First Technology FCU March 31,2019 2022 One 3-year extension
4 Hewlett Packard
Enterprise Company July 31,2020
6 Vacant,
will be State occupied
8
(Individually
metered)
Sykes Enterprises, Inc June 30, 2020 2025,
2030
Two five-year
extensions
STAFF COMMENTS JULY 5,2018
commercial tenants because it would likely exist even if the Campus buildings were individually
metered.
While a full service lease worked for the other commercial tenants and state agencies, HP
Inc. required that its lease include direct billing for its utility usage. HP Inc. believes this will
allow it to comply with Internal Revenue Code requirements regarding the sale and lease-back of
real property. In its original petition, IDOA proposed to separately sub-meter and bill HP Inc.
for its electrical consumption by installing "electric meters at the service side of each
transformer"5 and bill electrical use olhrough the protocols for reading the sub-meters developed
by the parties."6
But as the case progressed, IDOA learned that it could "duplicate the SCADA system
server at the Campus, and then use that server to log electrical use."7 This server would be
owned by the IDOA and provide 6,320 analog inputs which would allow very precise metering
of HP Inc.'s electric consumption.S This became IDOA's preferred option because it was the
least expensive and provided the most detailed usage data, though it confirmed that installing
either limited (8) or full (25) sub-meters to track usage were also possibilities.
Staff believes the SCADA server, perhaps combined with the other sub-metering options
described by the IDOA, can provide a very robust price signal that preserves the intent of master
metering rules. When coupled with the temporary situation, Staff believes these two factors are
sufficient basis on which to grant a limited waiver.
While Staff believes that the temporary status and preservation of the price signal are
critical to approving the waiver, Staff also points out that the price signal is only retained if
IDOA's billing methodology aligns with Idaho Power's billing methodology for Schedule 19.
That is not the case now, but Staff believes a feasible solution exists.
HP Inc. is being temporarily billed by IDOA for an allocated share of the cost of
electricity based on square footage until its actual energy usage can be segregated and measured.
Staff agrees with IDOA that this likely underbills HP Inc. for its electric use.e Staffunderstands
5 Production Response 2.
6 Petition at 9.
7 Production Response 2.
8 The Campus SCADA server performs equipment and operations monitoring and receives/records data and
operations information including current, load, voltage, temperatures, and equipment or process status. SCADA
systems are used by electric utilities to collect, record, and monitor data used to manage the elechic grid.
e Production Response 4.
9STAFF COMMENTS JULY 5,20T8
that after HP Inc.'s electric use is segregated and measured, IDOA still intends to bill HP Inc. on
an allocated basis, albeit a different one.
IDOA proposes to bill HP Inc. as follows: IDOA will determine what percentage of
kilowatt hours HP Inc. uses in relation to the total kilowatt hours measured by Idaho Power at the
primary meter. This percentage will be applied to the total billed amount reflected on Idaho
Power's bill for the Campus. This simplified billing methodology uses only one bill determinate
(kwh), but ignores demand, peak and off peak usage, and other components of Idaho Power's
Schedule 19. Staff maintains that IDOA's methodology will not reflect actual usage and is likely
to result in underbilling HP Inc. Staff believes that the sub-meters and/or the SCADA server will
allow IDOA to derive all the billing determinants and therefore bill HP based on all the
components of Schedule 19. This will avoid HP Inc. being subsidized by other Campus tenants,
including state agencies, and produce the accurate bill that HP Inc. has requested.
Because the price signal is not retained and HP Inc. cannot be accurately billed until the
IDOA billing aligns with utility billing, Staff recommends that the IDOA align its bill for HP
Inc. with Schedule 19. Staff is willing to work with IDOA to align its billing methodology with
Schedule 19. Staff recommends that when that process is complete, IDOA should submit a
compliance filing to the Commission to confirm the billing input and methodology align with
Schedule l9 and that the billing thereby most accurately retain the price signal. As pricing
inputs change within the Schedule 19, Staff recommends that the IDOA update its pricing
schedule. If this change is made, Staff believes the price signal will have been maintained and a
temporary waiver is justified.
Idaho Power's Construction Studies
As mentioned, IDOA authorized Idaho Power to study the investments required to align
the Campus with Idaho Power's electrical standards in order for the Company to enter into a
facility services agreement to serve the Campus. Idaho Power conducted two versions of this
study. Version 1 assumed that a master metering wavier was granted and Version 2 assumed
that a waiver was not granted and therefore each Campus building needed to be individually
metered. Under Idaho Power's facilities service charge arrangement, a customer can opt to have
the Company own and operate the electrical equipment on its system for an ongoing monthly
service fee. The ongoing monthly service is calculated based on 1.41o/o of the total investment
and extends indefinitely, although customers have the option to buy out of the contract.
STAFF COMMENTS l0 JULY 5,2018
Idaho Power estimated that Version 1 would cost approximately $1,311,508. Version 1
would maintain the POD at the Cloverdale substation and provide the necessary configuration
for Idaho Power to operate and maintain the Campus electric system through the Rule M
facilities charge if a waiver is granted. The cost for Version 1 would be paid through an ongoing
monthly facilities charge of $20,191 .
Idaho Power estimated that Version 2 would cost approximately $1,728,822 with an
ongoing monthly facilities charge of $ 1 1,812 for Idaho Power to operate and maintain the
facilities beyond the POD. Version 2 would install a POD at each building and each chiller to
establish a traditional metering arrangement that would not require a master metering waiver.
The total cost for Version 2 includes two components: a) an upfront payment of $891,081 for
distribution facilities under Rule H to individually serve each building;10 and b) an ongoing
monthly facilities charge of $ 1 I ,812 to pay the $837 ,7 4l investment for Idaho Power to install
facilities beyond the POD, which Idaho Power will then own and operate under the Rule M
facilities charge.
Both Version I and Version 2 estimates included disclaimers about the complexities and
unknowns that could not be precisely quantihed and fuither cautioned that contingencies, which
can be as high as 30Yo, were not included. The Company also pointed out that contractors' bids
could escalate substantially from this estimate.
Staff notes that the IDOA originally believed that a waiver was necessary to save
taxpayers the expense of individual metering. However, the bulk of the expense comes from the
investment required to align the Campus with Idaho Power electric standards so the Company
can provide facilities services. The Version 2 estimate, which does not require the waiver, is
about $417,000 more than Version I in total cost estimate.
However, the actual expense to the state, and ultimately taxpayers, is more accurately
reflected in the monthly facility costs. The monthly facilities charge for Version I is almost
double the monthly facilities charge for Version 2. Since the state will be responsible for
covering the facilities charge indefinitely, the smaller facilities charge under Version 2 will save
taxpayers money over the long term.
r0 Version 2 stated that a lgoh tax gross-up rate would apply to Rule H work exceeding $ 1 ,000,000.
STAFF COMMENTS 11 JULY 5,2018
Table 2: Idaho Power Construction Studies
Version 2 allows Idaho Power to serve the Campus through a facilities charge at a lower
total expense to taxpayers. In addition, it only requires a waiver until construction is completed
(54 weeks from the start date), significantly less than the 17-year waiver for Version l.
Individually metering the Campus buildings would also provide the IDOA more flexibility for
future use of Campus buildings.
Staff notes that one of the benefits of individual metering buildings is that it could
provide better price signals to tenants even if the state wishes to continue its practice of bundling
electricity costs into rent. Individual metering would enable IDOA to calculate rent for each
tenant based on actual electric usage of the building the tenant occupies, rather than simply
factoring in a proportional share of the aggregate usage of the Campus.
RECOMMENDATION
In accordance with Commission rules, Staff prefers direct metering when possible.
However, because the IDOA intends to transition the entire Campus to state occupancy and its
proposal to sub-meter with SCADA combined with Schedule l9 billing preserves the price
signal which underpins master metering rules, Staff believes it is reasonable to recommend a
waiver that would allow the IDOA to honor its interim lease agreements and facilitate the
transition to either individual metering or state occupancy. But to prevent future parties from
using this rationale to broadly circumvent master metering rules, Staff recommends the waiver
be granted with these limitations:
l. The waiver will expire when the Campus is individually metered, becomes wholly
occupied by State agencies, or when the existing lease extensions expire in2035,
whichever is earliest;
Idaho Power
Construction
Study
Total Cost
Estimate
Line Extension
(one-time)
Monthly
Facilities
Charge
Total Payments
10 years 20 years 30 years
Version 1 $ 1,3 1 1,508 $o $20,1 9 I $2.4
million
$4.8
million
$7.2
million
Version 2 $1,728,822 $891,081 $11,812 $2.3
million
$3.7
million
$s. I
million
STAFF COMMENTS t2 JULY 5,2018
2. The price signal associated with direct metering should be preserved by requiring
IDOA to make a compliance filing confirming the final Campus sub-metering method
and demonstrating that its calculations and billing methodology for HP Inc. aligns
with Schedule l9; and
3. The waiver should remain in effect only as long as the facility maintains similar use
as that under which it was granted.
fA
Respectfully submitted this 3 day of July 2018.
*.( / /t
Karl T. Klein
Deputy Attorney General
Technical Staff: Beverly Barker
Stacey Donohue
Rachelle Farnsworth
Rick Keller
Curtis Thaden
l:\umisc/comments\ipce I 8.Skkrkctrf comments
STAFF COMMENTS l3 JULY 5,20I8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5.h DAY OF JULY 2018, SERVED
THE FOREGOING COMMENTS OF THE COMISSION STAFF, IN CASE NO.
IPC-E-18-08, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
JULIE K WEAVER
DEPUTY ATTORNEY GENERAL
DEPT OF ADMISTRATION
PO BOX 83720
BOrSE ID 83720-0010
E-mail : j ulie.weaver@,ag.idaho. gov
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : caschenbrenner@ idahopower. com
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : lnordstrom@idahopower. com
[e-mail]
Y
CERTIFICATE OF SERVICE